Subject: File No. S7-14-08
From: Jim Chu
Affiliation: insurance broker

September 5, 2008

The fixed index annunity is not a security because it is not involved on any security of stocks, muture funds, options......

Fixed index annunity will not lose on principle and gain earned.

Fixed index annunity is totally ruled by state insurance deprtment already. Such as customer suitability.

So, fixed index annunity does not need and required to be ruled by proposed SEC 151a.